⚡ CASE DIGEST
Boyd v. Lee — Appellate Court of Maryland, 14 January 2026
An attorney filed a Maryland divorce appeal brief containing case citations that did not exist. Westlaw’s editors flagged the published opinion explicitly: the decision “contains discussion of citation references that are incorrect or do not actually exist.”
Why it matters: When Westlaw starts annotating published opinions to flag AI hallucinations, it signals the profession-wide scale of the problem — not just isolated incidents.
Category: Hallucinations & Sanctions | Jurisdiction: USA | Read time: 4 min
Case at a Glance
| Full Citation | Mataw Boyd v. Kimberly B. Lee, No. 1685, Sept. Term 2024 (Md. App.) |
| Court | Appellate Court of Maryland |
| Date of Decision | 14 January 2026 |
| Category | AI Hallucinations & Sanctions |
| Jurisdiction | USA |
| AI Tool Used | Not specified (citations flagged as non-existent) |
| Judgment / Order | Unpublished Opinion (2026 WL 111263) |
Background
Mataw Boyd, proceeding pro se in the circuit court, sought an absolute divorce from Kimberly Lee on grounds of cruelty. After the circuit court denied his complaint, Boyd retained attorney Troy, who filed an appellate brief on his behalf. The appeal had multiple procedural deficiencies, including failure to file required paper copies of the brief and record extract.
The AI Issue
Attorney Troy’s brief for the appellant contained case citations that the Westlaw editorial team flagged as “incorrect or do not actually exist.” These citations appear to be the product of AI-generated legal research that was not verified against an authoritative legal database. The court’s published opinion thus became another data point in the growing judicial record of AI hallucination in legal briefs.
What the Court Decided
- The court denied multiple post-hearing and post-judgment motions by the appellant [procedural failures].
- The circuit court’s denial of the divorce complaint was upheld on merits review.
- The Westlaw editor’s note preserved in the published opinion flags the non-existent citations, creating a permanent record of the hallucination [professional accountability].
- The opinion illustrates how AI-fabricated citations circulate through the appellate system even after trial-level proceedings.
Key Quote (Westlaw Editor’s Note)
“Editor’s Note: This decision contains discussion of citation references that are incorrect or do not actually exist. These invalid citations appeared in the original court opinion and have been preserved as written since they are part of the official court record.”
— Westlaw Editorial Note, Boyd v. Lee, 2026 WL 111263
The India Angle
Indian Law Equivalent: Fabricated citations in a brief before a High Court or the Supreme Court of India would constitute contempt of court and professional misconduct. Indian reporters like SCC, AIR, and the Supreme Court’s official reports are the authoritative sources — citing a case that does not appear in any of these would be verifiable and prosecutable.
Bar Council Rules: Rule 15 (duty not to mislead the court) and Rule 19 (duty not to deceive the client or the court) of the Bar Council of India Rules would be engaged. The publication of such cases in Westlaw-equivalent databases would create a permanent discoverable record for disciplinary authorities.
Practical Advice for Indian Advocates: As SCC Online and Manupatra integrate AI tools, advocates must independently verify every case citation before submission. The Maryland experience shows that even appellate-level briefs can carry AI hallucinations — no court is immune, and neither is any jurisdiction.
Quick Takeaways
- Westlaw now flags AI hallucinations in published opinions — creating a permanent professional liability record.
- Appellate briefs are as vulnerable to AI fabrication as trial-level filings.
- The verification duty applies equally to retained counsel and self-represented parties who later hire lawyers.